On the other hand, if one of the actual spammers were to just block downvoters and their downvotes, this would allow them to more easily evade detection as bad faith content creators. It's hard to say how that should be remedied beyond more moderation, which would require more unpaid mod labour and time. And relies on moderators always making fair and sensible decisions.
People and communities are tricky. Why do we all got to be so damn tricky?